To: Chief Executive Officers, CRA and Compliance Officers of All National Banks, Department and Division Heads, and All Examining Personnel

Description: Summary of Requirements

The attached document, "CRA Sunshine: Disclosure and Reporting of CRA-Related Agreements," is an executive summary of the final regulations implementing the Gramm–Leach–Bliley Act disclosure and reporting requirements for certain Community Reinvestment Act (CRA) agreements. The final regulations were published on January 10, 2001, and are effective on April 1, 2001. A copy of the final regulations also is attached. The executive summary includes a compliance chart designed to assist national banks and their subsidiaries in complying with the final regulations.

Background

The law requires each party to a covered agreement entered into after November 12, 1999, to disclose the agreement to the appropriate banking agency. Banks must disclose each agreement within 60 days of the end of the calendar quarter in which it was entered into by filing with the Office of the Comptroller of the Currency (OCC) either a copy of each agreement or a list of agreements entered into in that quarter. If a bank was a party to a covered agreement that terminated before April 1, 2001, it must disclose the agreement to the OCC by June 30, 2001.

The law also requires each party to a covered agreement entered into on or after May 12, 2000, to file an annual report concerning disbursement, receipt, and use of funds under the agreement. Generally, each party must file its report with the OCC within six months after the end of the fiscal year covered by the report. The bank must file its annual report with the OCC not later than June 30, 2001, for fiscal years that end between May 12, 2000, and December 31, 2000. If a nongovernmental entity that is a party to the agreement has provided its annual report to the bank, the bank must file that report with the OCC within 30 days of receipt.

Filing Procedures

National banks and other parties may disclose covered agreements and file annual reports with the OCC: